How the EPA’s

Refrigerant Management

Program Has Changed

Update to CAA:

Meet Your Moderator

Sylvia Leaphart

During this Webinar

All lines will be muted – please communicate via the

questions tab in your webinar panel.

There will be a Q&A session at the end of the

presentation – submit your question(s) anytime

throughout the webinar.

Slide deck and webinar recording will be sent to you

tomorrow.

Meet Your Presenter

Rick Foote

Agenda

Overview of the National Refrigerant Management Program

Highlight of Specific Changes

Outcomes of the Rule

Q&A

National Recycling and Emission

Management ProgramThe purpose of this program is to:

• Prohibit the release of CFCs, HCFCs, their

blends, and substitute refrigerants during service,

maintenance and repairs, and at end of life

• Reduce the use and emission of CFCs and

HCFCs

• Maximize the recapture and recycling of CFCs

and HCFCs

• Ensure the safe disposal of CFCs, HCFCs, and

their blends

Technician

Certification

Refrigerant

Sales

Restriction

Service

Practices

Recovery &

Recycling

Equipment

Recordkeeping

Repairing

Refrigerant

Leaks

Appliance

Disposal

Refrigerant

Reclamation

Phase Out of HCFCs

• Through the Montreal Protocol on substances

that deplete the ozone layer, the U.S. has

committed to a collaborative international effort

to end use of ozone-depleting substances.

• The U.S. phased out CFCs and halons in the

mid 1990s.

• EPA is currently in the process of reducing

HCFC production and import.

Timelines for Phase OutJanuary 1, 2010

• Banned production, import, and use of HCFC-22 and HCFC-

142b, except for continuing servicing needs of existing

equipment, achieving 75% of reduction goal.

January 1, 2015

• Ban on production, import, and use of all HCFCs, except for

continuing servicing needs of refrigeration equipment,

achieving 90% of reduction goal.

Which Refrigerants are Affected?• Ozone-depleting refrigerants (i.e., CFCs and HCFCs)

Currently subject to the Section 608(c) venting prohibition

Currently subject to the existing regulatory standards and requirements

• Substitute refrigerants (e.g., HFCs, HFOs, and PFCs)

Includes any substitute refrigerant not specifically exempted*

Currently subject to the Section 608(c) venting prohibition

Will be subject to the regulatory standards and requirements starting 2017,

2018, or 2019

• Exempt substitute refrigerants (e.g., ammonia and CO2)

Not subject to the venting prohibition in specific end-uses

Not subject to the regulatory standards and requirements in those uses

May be subject to other requirements (e.g., OSHA)

Exempt Refrigerants

End-Use and Application

Ho

use

ho

ld

Re

frig

erat

ors

Re

tail

refr

iger

ato

r st

and

-al

on

e V

end

ing

Ver

y L

ow

Te

mp

R

ef

He

at T

ran

sfe

r

Se

lf-c

on

tain

ed

Co

mm

erci

al

Ice

Mac

hin

es

Wat

er C

oo

lers

IPR

/pro

cess

ing

Ro

om

AC

- S

elf

-co

nta

ined

A

ll u

ses

CO2, N2, H2O

Ammonia

Hydrocarbons, Chlorine

Propane

Isobutane

R-441A

Ethane

Agenda

Overview of the National Refrigerant Management Program

Highlight of Specific Changes

Outcomes of the Rule

Q&A

Changes to Technician

Certification• You must be a Section 608 certified technician to open HFC appliances (starting

1/1/18)

• EPA is not requiring recertification of current technicians at this time

EPA is not changing the types of certifications

EPA is developing an updated test bank for certifying new technicians

• Certifying organizations must post a list of new technicians certified after 1/1/17

(starting 1/1/18)

Individual technicians can opt out

• EPA is removing the requirement that technicians certify that they own certified

recovery equipment (starting 1/1/17)

Changes to Sales Restriction• You must be a Section 608 certified technician

to purchase HFC refrigerants (starting 1/1/18)

• Refrigerant distributors may only sell HFC

refrigerants to certified technicians and must

maintain records for those sales (starting

1/1/18)

• Small cans (under 2 pounds) of refrigerant for

motor vehicle air conditioners (MVACs) are not

subject to the sales restriction or

recordkeeping requirement

Changes to Services Practices• Technicians must use certified recovery and/or recycling equipment

when opening an HFC appliance (starting 1/1/18)

• Technicians must evacuate to the specified levels of vacuum when

opening HFC appliances (starting 1/1/18)

• Newly manufactured or imported recovery and/or recycling

equipment models must be certified for use with HFCs (starting

1/1/17)

• EPA is adopting UL flammability standard as part of the certification

to ensure the safe use of recovery equipment designed for

flammable refrigerants (starting 1/1/17)

Leak Rates and Duty to Repair• Starting 1/1/2019, these modified leak repair requirements will apply to all refrigerants (excluding

exempt refrigerants cited earlier)

The existing leak repair requirements will continue as is for ODS appliances until 1/1/19

• The leak rate must be calculated every time refrigerant is added to an appliance containing ≥50 lbs.

of refrigerant

The repair requirements described on the following slides apply starting January 1, 2019, only if

over the threshold

• Revised leak rate thresholds:

30% for Industrial Process Refrigeration (IPR) (lowered from 35%)

20% for commercial refrigeration (lowered from 35%)

10% for comfort cooling (lowered from 15%)

• A certified technician must perform a leak inspection to identify the necessary repairs

• The repair must bring the appliance leak rate below the threshold

Must be demonstrated when calculating leak rate upon next refrigerant addition

Changes to Leak RepairVerification tests:

• Must demonstrate that leaks were successfully repaired

• Initial verification tests - done before refrigerant is added back into the repaired

appliance

• Follow-up verification tests - done after the repaired appliance returns to normal

operating characteristics and conditions

• Requirement extended to commercial refrigeration and comfort cooling (currently

required only for IPR)

• If either the initial or follow-up verification test indicates that repairs were not

successful, you may conduct as many additional repairs and verification tests as

needed within the 30-day repair period

Changes to Leak Repair• Definition of Appliance:

Clarifies that each independent circuit in a system with multiple circuits is a

separate appliance

• Leak rate calculations:

Provides that under the “Rolling Average Method” (formerly “Method 2”) in order

to “close out” a leak event the owner or operator must repair all identified leaks

and verify that the repairs have been successful.

• Recordkeeping:

Technicians must provide owners and operators with invoices (including

amount of refrigerant added), and results of leak inspections and verification

tests

Electronic recordkeeping encouraged

Changes to Appliance Disposal• Appliances with 5 pounds of refrigerant or less

Existing safe disposal requirements extended to HFC appliances (starting 1/1/18)

• Appliances with between 5 and 50 pounds of refrigerant

New records for the disposal of appliances containing between 5 and 50 pounds of

refrigerant (starting 1/1/18)

Company name, location of the appliance, date of recovery, and type of refrigerant

recovered for each appliance;

Amount of refrigerant (by type) recovered from all disposed appliances in each

calendar month; and

Quantity of refrigerant (by type) transferred for reclamation and/or destruction, the

person to whom it was transferred, and the date

• These records must be maintained by the technician and not the owner or operator of

the appliance

Agenda

Overview of the National Refrigerant Management Program

Highlight of Specific Changes

Outcomes of the Rule

Q&A

What are the Results of the

Changes?• By promoting the proper handling of refrigerants, EPA anticipates:

• The annual GHG emissions reduction is equivalent to the annual GHG emissions

of 1.5 million cars

• EPA estimates $44 million in savings from reduced purchases of refrigerant

What are the Results of the

Changes?• Consistent treatment of commonly used

refrigerants (e.g., ODS, HFCs, blends)

Incorporating best management

practices to reduce leaks from large

appliances

Focus on ensuring repairs are effective

Enhancing clarity of the rules to improve

compliance

Removing obsolete requirements

Flammable Refrigerants• EPA has exempted certain hydrocarbon refrigerants from the

venting prohibition when used in specific appliances and, as a

consequence, the Section 608 requirements:

These are new, self-contained, small appliances specifically

designed to use hydrocarbon refrigerants

EPA does not anticipate that opening up such appliances for

servicing or recharging will be common

Such appliances are identifiable by red tubing and other

markings

Flammable Refrigerants• It is illegal to use hydrocarbon or other flammable refrigerants

(such as R-22a) in existing HCFC/HFC appliances:

This is true whether the refrigerant is sold to a certified

technician or not

Some flammable refrigerants are not exempt from the

Section 608 requirements (such as HFC-32) and may only

be purchased by a certified technician

Recovery and/or recycling equipment for use with such

flammable refrigerants must be certified to ensure safety for

those refrigerants

Agenda

Overview of the National Refrigerant Management Program

Highlight of Specific Changes

Outcomes of the Rule

Q&A

QUESTIONS?

Thank You For Attending!

Rick Foote:

rfoote@triumvirate.com

Director of Industrial Practice

Triumvirate Environmental

Call Us!1-888-834-9697www.triumvirate.com

Triumvirate can help meet your compliance needs.

For more information on our consulting services, visit:

http://www.triumvirate.com/technical-

services/consulting-services